Interpretation ID: nht73-1.12

DATE: 10/23/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Trelleborgs Gummifabriks Aktiebolag

TITLE: FMVSS INTERPRETATION

TEXT:

This is in reply to your letter of August 22, 1973, responding to our reply of June 26, 1973, to your letter of May 28, 1973. We informed you in the June 26 letter that labeling a passenger car tire, "Max Load 1200 Lbs. At 36 psi," would not be consistent with Motor Vehicle Safety Standard No. 109 because this label does not make it clear that 36 psi is the maximum permissible inflation pressure. In your letter of August 22 you state that you have already manufactured tires labeled in this manner, and ask whether such tires may be imported into the United States in their present form.

The answer to this question is no. As we have determined that this labeling does not conform to Standard No. 109, the tires in question cannot be imported into the United States unless the labeling is modified to conform to the standard.

Sincerely,

U.S. Department of Transportation att: Assistant Chief Counsel National Highway Traffic Administration

August 22, 1973

Dear Mr Dyson:

Thank you for your letter of June 26, 1973. Our problem is that we already have manufactured a number of tires, labelled "Max load 1200 LBS at 36 PSI" without the word Max Press in front of 36 PSI.

My question: are we allowed to export these tires to the United States without any complications due to the not quite correct labelling? I can mention that we later on have changed to the correct labelling in accordance with your instructions.

Yours truly, TRELLEBORGS GUMMIFABRIKS AKTIEBOLAG Tire Development Department -- Erik Sundelin